INTRODUCTION
It is an undeniable fact that there has been a long standing controversy regarding the use of the prefix ‘ Dr.’ by Physiotherapists and Occupational Therapists in India. This controversy that has been in existence for years within the medical and allied healthcare sectors stemming from the misuse of the prefix ‘Dr.’ has led to the very dilution of the professional identity and has consequently resulted in confusion among the public. The Kerala High Court has revisited this long standing controversy once again in the case Indian Association Of Physical Medicine And Rehabilitation (IAPMR) v. Union of India and Ors, W.P.(C) No.41064 of 2025 through its interim order passed on 4th November 2025.
BACKGROUND
The instantaneous case could be traced back to the unresolved ambiguity that is in existence regarding the professional titles among various healthcare providers in India. Irrespective of the fact that Physiotherapists and Occupational therapists forms part of the allied health sector, they often claim to be primary or first-contact healthcare providers and, consequently, prefix “Dr.” before their names to indicate professional expertise. The aftermath of this misuse has resulted in tremendous confusion among the general public and professionals in the medical fraternity.
The instant Writ petition has been filed by the Petitioner Association, Indian Association Of Physical Medicine And Rehabilitation (IAPMR), which is an Association of medical doctors specialized in rehabilitation medicine, before the Kerala High Court with the humble prayer that physiotherapists or occupational therapists shall not be allowed to prefix ‘Dr’.
KEY POINTS
- The controversy over the usage of the prefix ‘Dr’ has primarily prefaced due to the inconsistency between the Indian Medical Degrees Act, 1916 and the Competency Based Curriculum for Physiotherapy and Occupational Therapy- Approved Syllabus, 2025. The Indian Medical Degrees Act, 1916 clearly stipulates and prohibits unqualified individuals from using the prefix ‘Dr’. However the Competency Based Curriculum for Physiotherapy and Occupational Therapy- Approved Syllabus, 2025 issued under the National Commission for Allied and Healthcare Professions has allowed the usage of the prefix “Dr.” for physiotherapists and occupational therapists. In the case of such a conflict, the primacy will undeniably be given for the statutory law which would override any kind of inconsistency in the curriculum guidelines.
- It is to be noted that pursuant to the Competency Based Curriculum, the Ministry of Health and Family Welfare has issued a Directive for the removal of the prefix ‘Dr’. This is owing to the fact that the Indian Medical Degrees Act, 1916 stipulates that only individuals possessing medical degrees recognized by the Government of India can legally use the prefix “Doctor.”
- Physiotherapists and occupational therapists are not legally qualified to use the title ‘Dr’ as they are not trained as medical doctors. The training and qualification of physiotherapists and occupational therapists, though highly skilled and essential, fall under the category of allied healthcare professions, which are secondary and are not independent medical disciplines.
- The Kerala High Court premised its interim order owing to the reasoning that Physiotherapists should not be permitted to primary care practice and should only treat referred patients, as they are not trained to diagnose medical conditions, some of which may worsen with inappropriate physiotherapy intervention. Though, physiotherapists play a vital rehabilitative role, they can in no way be equated with physicians or surgeons authorized to diagnose or prescribe medical treatment independently.
- It is important to note that section 6 of Indian Medical Degrees Act, 1916 condemns the unauthorized use of the prefix ‘Dr.’by individuals who doesn’t have a valid medical qualification. The unauthorized use of this title results in a legal violation and an uncontrollable extent of ambiguity among the patients and the general public. It is evident that the interim order passed by the Kerala High Court is upon duly considering the superiority of the statutory law and in the greater public interest.
RECENT DEVELOPMENTS
Justice V.G Arun passed the interim order dated 4th November 2025 in WP(C) NO. 41064 OF 2025 (G) directing the competent authorities to ensure that the prefix “Dr.” shall not be used by Physiotherapists and Occupational Therapists without recognized medical qualification.
This interim order is a prima facie recognition of the petitioner’s case and directs compliance from all relevant authorities until the next date of hearing, which is fixed for December 1, 2025.
CONCLUSION
It could be concluded that the Kerala High Court’s interim order is a significant step in clarifying the ambiguity regarding the professional identity and solidifies the diluted professional boundaries between medical and allied healthcare professions. Considering the essential role played by the Physiotherapists, a more appropriate and respectful title may be considered for graduates and postgraduates of physiotherapy, without causing ambiguity to patients or the public, however the usage of the prefix ‘Dr.’ absolves the whole concept of professional boundaries. In the instant case, due acknowledgment was given for the works rendered by the physiotherapists however the Kerala High Court took a firm ground that there cannot be an unauthorized use of the prefix ‘Dr.’ contravening the provisions of the Indian Medical Degrees Act, 1916.
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WRITTEN BY : AMYUKTA RAJAGOPAL
